- 4 - private letter ruling to the effect that petitioner was self- employed during the years in question. The Appeals officer agreed to “stay” the collection process while petitioner sought a ruling. Approximately 1 week later, the Appeals officer received a copy of petitioner’s request for a private letter ruling. The Appeals officer assumed that petitioner had submitted the original of the request for a private letter ruling to the appropriate Internal Revenue Service (IRS) ruling branch. The Appeals officer heard nothing further from or about petitioner until November 2000, when he received notification from within the IRS that an examination of petitioner’s employment status had been conducted and resulted in the conclusion that petitioner was an employee during the years in question. That determination had been made by respondent’s specialized examination group in Vermont that considers whether taxpayers are employees or independent contractors. It was at that time (more than 6 months after his telephone conversation with petitioner) that the Appeals officer discovered that petitioner had not sought a private letter ruling, but had instead submitted a request for examination of his status. After receiving the notification during December 2000, the Appeals officer caused the issuance of the notice of determination to proceed with the levy, from which petitioner appealed to this Court.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011